Strayhorn v. Raytheon E-Systems, Inc.

OPINION

JAN P. PATTERSON, Justice.

In this case, we must decide whether Raytheon E-Systems, Inc. (“Raytheon”) is entitled to a refund of sales tax under the “sale for resale” exemption of the tax code. Raytheon seeks the exemption for purchases of tangible overhead items charged as indirect costs to its contracts with the federal government. Carole Keeton Strayhorn, Comptroller of Public Accounts, and Greg Abbott, Attorney General of the State of Texas (collectively, “Comptroller”) 1 appeal, contending that the district court erred in concluding that Ray-theon was entitled to the refund. In a…